Palo Alto Comprehensive PlanTransportation Element Comments

Connecting VMT to the City’s goals for greenhouse gas emissions is an excellent policy. Complementary to T.1.1 and T.1.2.4 would be for the city to set mode share goals. In order to link development (# of residents and workers) to reduced impacts (less traffic, less demand for parking) there needs to be a comprehensive picture and set of goals for the share of people using transit, walking, biking, etc vs. driving.It is a major improvement to include reporting and compliance in the TDM policy. Palo Alto has had TDM policies for many years but they have underperformed due to lack of accountability. The list of TDM measures should include the funding of shuttles (which also appear in T1.12). Shuttle schedule data should be included in 511.org and Google Transit. The massive success of the Marguerite system is fostered by the fact that these shuttles are open to the public and their schedules are easily discoverable by the public. Regular surveying is an important addition. A cornerstone of the effective corporate TDM programs is regular, quantitative analysis of transportation use and options. The initial web-based survey is a good start but should be followed up with more rigorous representative sample surveys. Best-practice transportation studies - as done by Stanford, Google, Facebook analyze questions including: where do people come from and go to; what modes do they use today; what would enable people to switch to lower-impact modes.

District TDM plans and TMAs are good new proposed policies. They allow trip reduction investments to be shared among multiple developments, providing more robust services than any individual project could afford; they enable services for multi-tenant projects and a mix of uses. The TDM goals for individual developments should be set in such a way as to foster the achievement of the overall trip/VMT/modeshare/GHG goals. The Comprehensive Plan already recommends policies and programs for individual TDM plans for individual developments; the TMA ought to enable those investments to be made on behalf of all participants in the district. The draft mentions a TMA for downtown. The Comprehensive Plan should be more general; it should create a policy enabling the city to create TMAs for areas where the City has goals to reduce vehicle trips/VMT/GHG. This mechanism can then be deployed as needed, in areas that over time may also include Cal Ave, El Camino, South Palo Alto (where Google is adding many more employees), etc.

For TDMs, and TMAs a rigorous data collection and analysis infrastructure is vital and indispensible. Specific policies and programs should be based not on proposed traffic models & projections, and/or outdated historical data older than 2+ years. The policies and programs of the Comp Plan should be informed through scientifically collected, empirical data gathered at more frequent and regular intervals. At a minimum, quarterly reports can help validate and enforce TDM policies and programs and more accurately gauge trends; more frequent data would be even better and filter out seasonal fluctuations. TDM programs are iterative by nature. Creating a tighter, more frequent data collection/analysis feedback loop is critical to improving TDM programs and adapting them as economic conditions and needs on the ground change. With a robust comprehensive mechanism for collecting traffic and transit data for an area such as Downtown or California Avenue, aggregated impacts can be continuously assessed, and specific projects need to be subject to arbitrary reporting requirements. Policy T4.7.2 suggests that data only needs to be collected for five years - but limiting to 5 years is contrary to the best practice examples of employers such as Stanford and cities such as Boulder. High performing TDM policies have shown continuous improvement over 10-20 years. It is counterproductive to stop measuring after five years.It’s good to see Residential district parking addressed (T4.5), but the language can be stronger and should be more integrated with business district parking policies. The two issues of parking in business district and traffic impact in residential neighborhoods are linked and should not be divorced. The Comprehensive Plan should support broad parking districts in residential areas adjacent to business districts and call for careful evaluation of how parking pricing (or lack thereof) in residential areas adjacent to business districts or transit corridors affect parking supply/intrusion and traffic impacts. Great to see T1.13 about inclusion of public school commute patterns in local transit system. Can private schools like Castelleja should be included in this too? Currently, the Palo Alto shuttle misses the Palo Alto high school start time by 2 minutes. Shuttle service to and from the correct nodes can help congestion at places like Castelleja and Gunn given recent concerns in Old Palo Alto and Charleston/Arastradero neighborhoods for traffic generated by those respective schools. We should also not underestimate the number of car trips generated by parents of younger children, particularly to Jordan MIddle, Walter Hays, Barron Park, El Carmelo Elementary schools, which often require children to cross busy arterials and Ohlone which supports students all across town.Encouraging to see Policy T1.18 which prioritizes pedestrian access and bicycle use within Palo Alto and surrounding communities. Many of the supporting programs for this policy seem to favor options that support these transport modes on side streets or alternate pathways. That is fine goal. However, bike & pedestrian improvements should also be integrated on busy arterials as part of a complete street configuration, especially along El Camino Real, which is part of the Grand Boulevard Initiative. There are also opportunities for making similar improvements along Alma, Middlefield, Page Mill/Oregon, Meadow, Charleston/Arastradero. Locations on these thoroughfares are important retail, commercial, and residential destinations. To make cycling a mainstream transportation mode, it is important to integrate safe pedestrian and bicycle access to the locations people use. And integrating cycling along busy thoroughfares can help make overall streets safer for all users.Harmonize T4.6 and T4.7 which appear to be at odds. “All new development projects should be completely self-parked” and “Continue to encourage shared parking and offsite parking agreements in order to reduce the overall number of new parking spaces that must be provided on site for new development.” T4.6 should be modified to say “incorporating the use of shared and offsite parking per 4.7.”T5.7 POLICY The measurement of bicycling and walking is included under “safe routes to School.” Given the high current bicycle mode share and the city’s goals, measurement should be for overall cycling, not just for children/families. Identify and deploy technology to monitor sidewalks and bicycle facilities to help identify trends in multimodal use at schools, parks, and other community facilities. (New Program)The specific mention of Light Rail in T7.19 is an interesting idea. However, in practice, there is already approval for a Bus Rapid Transit option through Palo Alto, albeit a mixed flow option. Practically, wouldn’t it be a more cost effective approach to support dedicated BRT travel lanes through PA along El Camino instead of mixed flow BRT AND Light Rail. Light rail is currently not even a time efficient option between MV and SJ and would be a very costly project to extend to Palo Alto. At this point & time this seems like a poor area of focus for staff time & political will. All in all, it does feel like these Comprehensive Plan revisions are moving us in the right direction to manage the difficult transportation challenges Palo Alto is facing. We hope that there will also be adequate funding and staff/community resources dedicated to realizing these policies and programs. While we recognize this is not the purview of the Comp Plan, we hope that financial allocations will be made in future budgeting processes to execute these policies & programs and execute them well.